Contractor Cannot Claims for Increased Costs Due to Delay Obtaining Performance and Payment Bonds for Construction Work; ASBCA No. 60686, Appeals of K-Con Inc.

Appeals of the government’s denial of claims for increases in the cost of materials and labor due to a delay in the issuance of a notice to proceed is denied, where FAR provisions requiring construction contractors to obtain payment and performance bonds were deemed incorporated into the contract under the Christian doctrine and the appellant was responsible for the delays in obtaining them.